LOCKOUT / TAGOUT

You Have a Lockout Program. You Probably Do Not Have Procedures.

The standard requires energy control procedures specific to each machine. Most companies have a general program and nothing behind it — which is exactly what gets cited after someone is caught in a machine.

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1910.147 energy controlMachine-specific proceduresAuthorized employee trainingAnnual inspections
THE USUAL FINDINGS

Six failures show up in almost every LOTO audit.

No equipment-specific procedures

A general program describes the policy. The standard requires documented procedures identifying the energy sources, isolation points and verification steps for each machine. This is the most common citation in the standard.

Stored energy ignored

Pneumatic pressure, hydraulic accumulators, gravity, springs and capacitors kill people after the electrical disconnect is locked. Procedures that stop at the breaker are incomplete.

No annual procedure inspection

The standard requires a periodic inspection of each energy control procedure by an authorized employee other than the one using it, documented. Almost nobody does this, and it is easy for an inspector to request.

Authorized versus affected confusion

Training requirements differ between authorized, affected and other employees, and records need to show who received which. Blanket annual training for everyone does not satisfy it.

Contractors and outside crews

When outside servicing personnel work on your equipment, both sides must inform each other of their respective procedures. This is routinely undocumented.

Group lockout and shift change

Multi-person servicing and shift handover require specific provisions. Companies that do single-person lockout well often have nothing written for the group case.

WHAT WE DO

We write the procedures machine by machine, from the actual equipment.

We survey each machine, identify every energy source including stored energy, document the isolation points and verification steps, and produce a procedure that an authorized employee can actually follow at the machine — usually with photographs of the isolation points.

Then we build the parts that make it hold: the authorized employee training and records, the annual inspection process and documentation, the group lockout and shift-change provisions, and the contractor coordination language.

Deliverables

  • Energy control program reviewed or rewritten
  • Machine-specific procedures with isolation point photos
  • Stored energy identification and release steps
  • Authorized and affected employee training with records
  • Annual periodic inspection process and forms
  • Group lockout and shift-change provisions
  • Contractor coordination protocol
FAQ

Lockout/tagout questions

Does every machine need its own procedure?

Nearly. There is a narrow exception for equipment with a single energy source that is readily identified and isolated, with no stored energy and no potential for reaccumulation, among other conditions. Most production equipment does not qualify, and assuming it does is a common error.

Can one procedure cover identical machines?

Yes, if they are truly identical in energy sources and isolation points. Differences in installed utilities or retrofits break that, so identical model numbers are not sufficient on their own.

How often must authorized employees be retrained?

When the procedure, machine or job changes, and whenever a periodic inspection reveals a deviation. There is no automatic annual requirement for retraining, though the annual procedure inspection is required.

What about cord-and-plug equipment?

Equipment under exclusive control of the person servicing it via unplugging is treated differently, but exclusive control is the operative condition and it is often assumed rather than achieved.

How long does a full LOTO build take?

Depends on machine count. Roughly fifteen to thirty procedures per week of survey work, plus review and training rollout.

Count your machines. Count your procedures.

If those two numbers do not match, that gap is your exposure. Twenty minutes to scope closing it.

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